Upload
others
View
6
Download
0
Embed Size (px)
Citation preview
Loan No. 3045-BAN-OCR
Public-Private Infrastructure Development Facility-II
ANNUAL ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT REPORT
110 MW Power Project at Rupatali, Barisal, Bangladesh
Summit Barisal Power Limited
March, 2020
Prepared by
INFRASTRUCTURE DEVELOPMENT COMPANY LIMITED
DHAKA, BANGLADESH
www.idcol.org
2| P a g e
TABLE OF CONTENTS
Executive Summary…..………………………….…………………………………..……………..6
1. Introduction………..………….………………….……...………………………………………..7
1.1 Project proponent.…….…..……………….…….…….……………...…………….…………………7
1.2 Area and location of the project…………..…….…………...………………….…….………..…….7
1.3 Brief description of the project……………..…………….………………………….…….…..…..…8
1.4 Operational status of the project……………..…………….………………………….…….…..…...8
1.5 Objectives of environmental and social compliance audit……..…….………….………..……….9
1.6 Methodology ….………………………..……………………………………….………...……..…….9
1.7 Reporting period………………………..……………..………………………….……..……………..9
1.8 Changes in project scope……………..……………………………………….………....…………..9
1.9 Environmental monitoring ……………..………………………………….…….……..……………..9
2. Regulatory Requirements………………………………………………………………………………..10
2.1 ECR, 1997 of Bangladesh Government………………………………………………………..… 10
2.2 SPS, 2009 of Asian Development Bank……………...……………….…..……………….………10
2.3 ESSF of IDCOL………………………………………………………………….……………………10
3. Implementation of Environmental Safeguards………………………….……………………………11
3.1 Compliance with ECR, 1997…………………………..…………..…………………….…….……11
3.2 Compliance with EMP……………………………………………………………………….……….11
3.3 Compliance with ADB requirement……………….…………………………………….………..…16
4. Implementation of Social Safeguards…………………………………………………..…………..…17
4.1 Impact on resettlement and livelihood ….…………………………………………………….……17
4.2 Institutional arrangement for social safeguards ………………………………………….……….17
4.3 Grievance redress mechanism………………… ………………………………………….……….17
4.4 Impact on indigenous people………………….. ………………………………………….……….17
4.5 Child labour…………………………………..………………………………...………….….………17
4.6 Public consultation and disclosure of information …………...……………...……………………19
4.7 Enhancement …………...……………...…………………………………………………………….19
5. Corrective Action Plan ……….………...……….……………………...…….………………………….20
6. Conclusion…………………………………….………………………………….………………….…..…21
3| P a g e
Annexure
Annex-1: Renewal of Environmental Clearance Certificate.…………………….……...………………...22
Annex-2: Location of the project site……...……………………….…………….…….…….………………23
Annex-3: Project risk rating checklist of ESSF, IDCOL……….………….………….………………….…24
Annex-4: PPE arrangement……………...…….…………….…….………….………….………………..…25
Annex-5: Fire fighting arrangement.………………………..….………….…….…….………………..…...26
Annex-6: Application of signage(external view)……….……………………………………………………27
Annex-7: Current status of project(internal view)…………….…….…….……………………………...…28
Annex-8: Application of signage………………………………………...…………….….….………….……29
Annex-9: Effluent treatment plant……………………….……………………………………..….…….…..30
Annex-10: House- keeping ………………………………………………………….……….…………….…31
Annex-11: Embankment protection arrangement……………………………….………………………….32
Annex-12: Landscape………………………..…………………………………….………………………….33
Annex-13: Stakeholder consultation by IDCOL Official.…………………….……………....….…….……34
4| P a g e
List of Abbreviations
ADB Asian Development Bank
DOE Department of Environment
ECR Environment Conservation Rules
EHS Environment and Health Safety
EMP Environmental Management Plan
ERP Emergency Response Plan
FGD Focus Group Discussion
IDCOL Infrastructure Development Company Limited
IEE Initial Environmental Examination
PPE Personal Protective Equipment
SBPL Summit Barisal Power Limited
SPS Safeguards Policy Statement
5| P a g e
List of Tables
Table 1.1: Key project information……………………...………….………….…….…..…..………………...7
Table 1.2: Project site surrounding feature.………..……..…………………………..…..….………………8
Table 1.3: List of major machineries…...……………………….……………..…..……..…..……….………8
Table 3.1: Compliance with ECR, 1997.…….…………..….… ……………………….………………...…11
Table 3.2: Response of SBPL on project activities and mitigation measures during operation…….…12
Table 3.3: Monitoring parameters and frequency ….…………………………….………….….……….…14
Table 3.4: Ambient air quality at project site ……………………….……………….………………………14
Table 3.5: Ambient noise level at project site ………………………...…………….………………………15
Table 3.6: Surface water quality at project site …………………………,…....………………….…..……15
Table 3.7: Ground water quality at project site ………………………..…,…..…………….………..…….15
Table 3.8: Compliance with important EHS aspects during operation……….………………….……….16
6| P a g e
EXECUTIVE SUMMARY
Background
Summit Barisal Power Limited (SBPL) has been awarded through a competitive bidding
process to develop and operate an independent power plant project with capacity of 110 MW
at Rupatali, Barisal District. For financial assistance SBPL has approached Infrastructure
Development Company Limited (IDCOL), along with other lenders. Considering the
importance of the project to meet the national power demand, IDCOL has provided a term
loan facility of USD 30 million in favour of the project. IDCOL has sourced the required
financing from the fund allocated as ordinary capital resources (OCR) for large infrastructure
projects under Public-Private Infrastructure Development Facility (PPIDF)-2 of Asian
Development Bank (ADB).
According to the Environment Conservation Rules (ECR), 1997 of Bangladesh Government,
industrial projects have been categorized into four classes—Green, Orange A, Orange B and
Red. Considering the magnitude of environmental impacts, power plant project has been
classified as Red Category. Hence, SBPL project has fallen into the Red category. Given the
environmental impacts of the SBPL project are mostly site specific, ADB has categorized the
project as B as per ADB guidelines. Due to the absence of any indigenous habitat in the project
area, the project has been categorised as C from indigenous peoples (IP) perspective. But as
there were no issues in relevant to involuntary resettlement or adversely affecting livelihood, ,
the project has been categorised as C from involuntary resettlement (IR) perspective. In
addition, IDCOL has adopted an Environmental and Social Safeguards Framework (ESSF).
According to this ESSF, the proposed project of SBPL seems to be a High Risk project
requiring detail environmental impact assessment.
Bangladesh Centre for Advanced Studies (BCAS) being engaged by SBPL as Environmental
Consultant, has conducted the detail environmental impact assessment and prepared the
Initial Environmental Examination (IEE) Report based on the guidelines of Department of
Environment (DOE), Government of Bangladesh (GOB) and Asian Development Bank’s
(ADB’s) Safeguard Policy Statement (SPS), 2009. In addition, as there was a plan to seek
investment of International Finance Corporation (IFC), SBPL has also complied with the
respective IFC EHS guidelines (general and sector specific).
To assess the actual implementation of environmental management plan and social
safeguards, respective IDCOL official visited the project site during construction and operation
phases. According to the IEE, there is requirement of IDCOL to submit annual Environmental
and Social Compliance Audit Report of this project to ADB. Accordingly, this audit report has
been prepared by IDCOL.
Audit overview and findings
The respective IDCOL official has visited the project during the audit period (January 2019 to
December 2019). He has also reviewed the available relevant documents and clearances. In
addition, there was consultation with representatives of adjacent neighborhood. During audit,
the commitment of SBPL to comply with environmental and social safeguards have been
found as satisfactory.
7| P a g e
1.0 INTRODUCTION
1.1 PROJECT PROPONENT
The project involves development and operation of a 110 MW HFO based power plant at
Rupatali, Barisal by Summit Barisal Power Limited (SBPL). SBPL is a special purpose vehicle
of well-known entrepreneur named Summit Group. The generated electricity from the project
will be sold to Bangladesh Power Development Board (BPDB) under a 15-year Power
Purchase Agreement. Table 1.1 shows key project information.
Table 1.1: Key project information
Project Company Summit Barisal Power Limited
Project Location 25 No Ward, Rupatali, Barisal City Corporation, Barisal
Plant capacity 110 MW
Raw material HFO
Source of raw material Import
Required quantity 1,43,000 MT/year
Water requirement 100 m3/hr
Land Area 9 acres
Project Tenure 15 Years
Project Type Independent Power Producer
1.2 AREA AND LOCATION OF THE PROJECT
The majority portion of the proposed power plant will be located at Rupatali, Barisal and a
certain portion of land has fallen under the jurisdiction area of Nalchity Upazilla in Jhalokati
District of Barisal in Bangladesh. The location map and project location in geological map, soil
map, agricultural map, agro-ecological map and surrounding pictures are given below.
The site is situated in the North-Western side of Barisal-Barguna Highway and Barisal-Pirojpur
Highway and at a distance of 1.5 kilometer from Barisal-Barguna Highway and 1 kilometer
from Barisal-Pirojpur Highway. The present location is at a distance of 3 kilometer from the
Barisal city which is south-east to the proposed site. The place is known as ward no. 25,
Rupatali. The site is adjacent to existing pucca road of 15 feet, which connects this side of
ward no. 25, Rupatali, Barisal. The site is also adjacent to Kirtonkhola River. This river is the
most vital river of Barisal as a main route for transporting raw material and other commercial
purposes.
8| P a g e
Table 1.2: Project site surrounding feature
Side Object Coordinate points Coordinate
Northern Canal NE corner 22°39'25.43"N 90°20'8.60"E
Southern Opsonin & PDB SW corner 22°39'20.72"N 90°20'14.88"E
Eastern Settlement and open space SE corner 22°39'26.82"N 90°20'11.95"E
Western Kirtonkhola River NW corner 22°39'22.79"N 90°20'8.41"E
1.3 BRIEF DESCRIPTION OF THE PROJECT
The power plant uses HFO as fuel. The project comprises seven (6) numbers of Wartsila made
18V46 reciprocating type heavy fuel engines. The engine is of the four strokes, direct injected,
piston, turbo charged and intercooled design. The optimized fuel injection system contributes
to complete combustion of all fuels over the entire load stage. Fuel oil operation is based on
the use of normal fuel oil injection pumps and can run on crude oil, LFO or HFO. Where, HFO
is the main source of energy. Fuel sharing is available between 35% and 87.5% of rated load.
Operational software consist of PLC based WECS system (details attached) is a fully
integrated engine control system, designed for harsh environments. The system is built on the
engine and handles all necessary monitoring, control and protection functions needed on the
engine. The system architecture is based on distributed electronic modules, with
measurements and controls occurring locally where needed on the engine.
Power dispatches is done as per provision of the PPA. The plant is connected with the nearby
132 KV Substation of PDB. Through this substation, electricity generated by the plant will be
distributed to the greater Barisal.
Radiator cooling system has been installed and therefore there is no need to extract cooling
water from surface water. The stack height has been designed at 50 meters to ensure effective
dispersion of the emissions which minimizes the air pollution impact in the area and to comply
with the national and international standards. The specifications of the the engines and
generatorsare shown in the the following Table 1.3
Table 1.3: List of major machineries
Component Manufacturer/ Country Model / type
Reciprocating Engine WARTSILA / FINLAND 14G46
Generator ABB / GERMANY (or equivalent) AMG 1121 M
Control system WARTSILA / FINLAND WOIS
9| P a g e
1.4 OPERATIONAL STATUS OF THE PROJECT
The project has been meant for generating 110 MW of electricity. But due to variation of power
demand from Bangladesh Power Development Board, in most of the time of the year the
project was not required to generate maximum output. However, throughout the year, the plant
was technically capable to generate 110 MW of electricity.
1.5 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT
The audit has been conducted with the aim to assess the project’s compliance with-
(i) Environment Conservation Rules (ECR)1997 of GOB;
(ii) Environmental and social safeguards according to the Environmental and Social
Safeguards Framework (ESSF) of IDCOL;
(iii) Environmental and social safeguards according the Safeguards Policy Statement
(SPS), 2009 and other relevant standards and guidelines of the ADB;
(iv) Proposed mitigation measures and monitoring procedures according to the
environmental management plan (EMP), resettlement action plan (RAP) as are
applicable.
1.6 METHODOLOGY
The audit includes the following steps:
(i) visit the project site and consult with stakeholders especially local people;
(ii) review the environmental and social safeguards documents including environmental impact assessment report, EMP and and so on (as are relevant) ;
(iii) assess actual implementation of the guidelines/action plan of the safeguard related
documents.
1.7 REPORTING PERIOD
The reporting period of this Environmental and Social Compliance Audit Report is January
2019 to December 2019.
1.8 CHANGES IN PROJECT SCOPE
There is no change in the technology and operational process as have been declared by the
respective government and accepted by SBPL. So, it can be said that the Environmental
Management Plan (EMP) of ADB approved Initial Environmental Examination (IEE) is fully
applicable during the reporting period as well.
1.9 ENVIRONMENTAL MONITORING
The parameter, frequency and methodology of environmental monitoring are in accordance
with EMP of ADB approved IEE, as has been detailed in chapter 3 of this audit report.
10| P a g e
2.0 REGULATORY REQUIREMENTS
2.1 ENVIRONMENT CONSERVATION RULES, 1997 OF BANGLADESH
The project has to comply with the Environment Conservation Rules (ECR), 1997. According
to the categorization of ECR, 1997, the project has been categorised as Red1 meaning that it
has significant adverse environmental impacts, which are to be mitigated with proper
mitigation measures.
2.2 ENVIRONMENTAL AND SOCIAL COMPLIANCE RELATED STANDARDS AND
GUIDELINES OF ASIAN DEVELOPMENT BANK
The project has to be complied with Safeguards Policy Statement (SPS), 2009 of ADB in
regard of environmental and social (E&S) compliances. Considering the adversity of
environmental impacts, it has been categorized as B from environmental safeguard point of
view. Accordingly an IEE has been prepared, which is already approved by the ADB. As no
record of any indigenous habitat has been found at Rupatali, Barisal the project has been
categorised as C in respect of Indigenous People (IP).And as there is neither any issue of
involuntary resettlement nor adversely affecting livelihood of any community or person, the
project has been categorised as C in repest of Involuntary Resettlement (IR) issue.
2.3 ENVIRONMENTAL AND SOCIAL SAFEGUARDS FRAMEWORK OF IDCOL
IDCOL has adopted an Environmental and Social Safeguards Framework (ESSF) in 2011,
which is to be complied with all infrastructure projects as are to be funded IDCOL. According
to the environmental categorization of ESSF, the project has been categorised as High Risk2
project requiring significant compliance safeguards including comprehensive environmental
impact assessment and regular monitoring. In consideration of social categorization, the
project has been categorised as Low Risk in consideration of social safeguards as there is
neither issue of indigenous people nor involuntary resettlement..
1 Schedule-1 of ECR (project no. 6 of Red category), 1997
2 The project risk screening checklist of ESSF, IDCOL is provided in Annex-3
11| P a g e
3.0 IMPLEMENTATION OF ENVIRONMENTAL SAFEGUARDS
3.1 COMPLIANCE WITH ENVIRONMENT CONSERVATION RULES, 1997
SBPL has to comply with the requirement of ECR, 1997 of the DOE. In the following Table
3.1, the compliance status of SBPL, in regard of major milestones of ECR, 1997 is depicted.
The renewal copy of Environmental Clearance Certificate is provided in Annex-1.
Table 3.1: Compliance with the requirement of ECR, 1997
Basic Requirement Compliance Status
Award Site Clearance Certificate Fully complied
Award EIA approval Fully complied
Award Environmental Clearance Certificate Fully complied
Renewal of Environmental Clearance Certificate Fully complied
3.2 COMPLIANCE WITH ENVIRONMENTAL MANAGEMENT PLAN
a. Institutional arrangement
At present, Mr. ali ahsan, plant Mnaager is playing the role of EHS Manager. Because Mr. Md.
Shofiul Alam as Assistant Deputy Manager (HSE) has left the job.
b. Compliance status
In the IEE, a number of activities having potential adverse environment impacts and
occupational health safety aspects during operation phase have been identified. In the
following Table 3.2, suitable mitigation measures to address these impacts according to the
EMP and actual responses by SBPL has been discussed.
Table 3.2: Response of SBPL on project activities and mitigation measures during operation phase
Project Activity Potential Impacts Mitigation Measures Actual Implementation Compliance status
Air emission, noise generation
Emission from the power plant
Install stack emission monitoring equipment for major pollutants; Plant indigenous trees around the Project site
Trees have been planted and quarterly air quality is monitored.
Fully complied
Generation of noise from generators and associated sub-stations , which could exceed 70 dB(A) at site boundary
Locate facility 70–100 m from nearest receptor; Use walls, fencing, and/or greenbelt to provide partial noise
barrier; Provision of critical silencers or generators (if need arises); Use of ear-muffs and ear-plugs by plant personnel working in the
generator and turbine facilities of the plant.
Through using new generators and ensuring proper application of walls, fencing and green belt, noise level is within the acceptable limit.
Fully complied
Suspended particulate matter (SPM) and PM2.5, PM10, NOx, CO, VOC generation from the engine, which can adversely affect health
Good combustion control, required stack height should also be maintained properly .
50m high stack has been introduced, which has sufficiently addressed the air emission including SPM and others.
Fully complied
Occupational Health and safety
Solid wastes Apply the waste hierarchy and reduce, reuse or recycle wastes
wherever possible; Segregate wastes by types and provide appropriate waste
containers for the storage of all waste streams.
Proper waste management has been observed, which includes segregation of wastes at source.
Fully complied
Hazardous Materials Management
Refueling, washing and maintenance of plant and vehicles will be prohibited in the vicinity of water bodies;
Spill kits will be available to contain any accidental release of hazardous materials;
All hazardous materials will be provided with secondary containment.
Spill kits were found to wash with due attention.
Fully complied
Application of PPE Ensure satisfactory PPE for workers, officials and visitors
There are satisfactory use of PPE Fully complied
13| P a g e
Project Activity Potential Impacts Mitigation Measures Actual Implementation Compliance status
Disaster
Management,
Fires, explosion
and other
accidents
Emergency Response (i.e. Fire, Earthquake, Flood etc.)
Use of personal protective equipment during operation and maintenance;
Prepare and implement safety and emergency manual;
Regular inspection of lines for faults prone to accidents;
Provision of fire protection equipment;
Provision of Lightening arrestors.
There are application of different types of fire extinguishers, fire hydrant and regular training arrangement
Fully complied
Domestic wastewater, sewage and sanitary waste
BOD, fecal coliform contamination in groundwater and surface water
Need to provide septic tank with soak pit for treatment of sewage; Provision of an appropriate number of toilets and hand-washing
points; Provision of on-site treatment of sanitary wastes; Training on sanitation practices.
There is adequate number of toilets with septic tank facility.
Fully complied
Wastes oil from Plant (scrap metal, waste, lube oils, spill oil etc)
Potential soil and groundwater contamination
Secure on-site storage, waste sell to the DOE authorized vendor for discharge in a safe place.
The waste lube oil and spill oil are sold to DOE authorized vendor.
Fully complied
Public Relations & Stakeholder Engagement
Emergence of grievance
Conduct proactive public relations (PR) exercises consisting of news/information dissemination to increase understanding of the project.
SBPL communicates with society occasionally
Partially complied
c. Environmental monitoring
I. Technical approach of environmental monitoring
In the EMP of the IEE, environmental monitoring has been required during operation phase.
The air, water and noise quality monitoring schedule are depicted in Table 3.3.
Table 3.3: Monitoring parameters and frequency of monitoring during operation phase
Key parameters to be monitored: (1) Ambient Air Quality
location frequency parameter
At Project site, residential /institutional /commercial areas within 500m outside from plant boundary.
Quarterly (routine) analysis SPM, SOx, NOx
Key parameters to be monitored: (2a) Surface Water
location frequency parameter
Project site at Rupatali Bi-annual basis in each year (pre-monsoon and post-monsoon)
pH, Temperature, DO, BOD, COD, TDS, Oil and grease
Key parameters to be monitored: (2b) Ground Water
location frequency parameter
Project site at Rupatali Bi-annual basis in every year (pre-monsoon and post-monsoon)
pH, Temperature, DO, BOD, COD, TDS, Oil
and grease
Key parameters to be monitored: (3) Noise
location frequency parameter
At four corners of Project boundary, residential/institutional /commercial areas within 100m and 300m outside from plant
Quarterly (routine) analysis Limits in dBA
Table 3.4: Ambient air quality at project site
Location 28 May 2019 22 September 2019
PM10
(µg/m3)
SOx
(µg/m3)
NOx
(µg/m3)
PM 10
(µg/m3)
SOx
(µg/m3)
NOx
(µg/m3)
At project site 107 33 29 101 31 20
Standard of DOE 150 365 100 150 365 100
Source : SBPL
15| P a g e
Table 3.5: Ambient noise level at project site
Location 30 March 2019 22 september 2019
Day (6.00 am to
9.00 pm)
Night (9.00 pm
to 6.00 am)
Day (6.00 am to
9.00 pm)
Night (9.00 pm to
6.00 am)
Northern side of the plant 66 62 68.1 58.3
Southern side of the plant 69 68 67.5 57.9
Easrtern side of the plant 65 64 65.7 56.2
Western side of the plant 66 65 67.9 57.5
Standard of DOE3 75 70 75 70
Source : SBPL
Table 3.6: Surface water (ETP) quality at project site
Parameter 15 February 2019 22 September 2019 DOE Standard
pH 7.4 7.6 6-9
Temperature 230C 26.60C 400C
BOD 22 mg/l 28 mg/l 50 mg/l
COD 70 mg/l 84mg/l 200 mg/l
Source : SBPL
II. Result of environmental monitoring
During operation phase, the ambient air quality has been found to comply with the acceptable
limit of DOE. The surface and ground water quality have been found to be within the limit of
DOE. In addition, the noise level has also been found to be within the acceptable limit.
III. Disclosure of environmental monitoring
As disclosure of environmental monitoring, SBPL has kept the copy monitoring result available
at project site.
IV. Monitoring adjustment measure
As the result of air, water and noise level monitoring have been found to be within the
acceptable limit, application of any adjaustyment/mitigation measure has been required.
3 The project area has been considered as Industrial Zone based on landuse
16| P a g e
3.3 COMPLIANCE WITH SAFEGUARDS POLICY STATEMENT, 2009 OF ADB
It is already said that the SBPL project has to comply with the requirement of SPS, 2009 of
ADB. Accordingly, the compliance of this project in regard of major EHS related requirement
are mentioned in Table 3.8.
Table 3.8: Compliance with important EHS aspects during operation phase
ADB
Requirements
Issue and Description of Observation compliance
Status
Environment
Assessment
requirements for
various financing
modalities
SBPL has adopted an EHS Implementation Guidelines, which could be enhanced
by incorporating the IFC EHS Guidelines (general and project specific) in a more
structured manner.
Fully complied
Occupational and
Community Health
and safety
SBPL has ensured the satisfactory application of PPE. Fully complied
There is satisfactory evidence of fire drill. Fully complied
Biodiversity
conservation and
sustainable natural
resource
management
The activities in relevant to operation phase seems to be inadequate to adversely
affect the biodiversity and natural resource management in the project area to a
greater extent. But due to the long term operation of the project, there could be
limited/minimal impact to the local biodiversity.
Fully complied
Pollution prevention
and abatement
SBPL has conducted air, water and noise quality monitoring. Fully complied
Spillage management process has been found as satisfactory. Fully complied
Physical Cultural
resources Due to the unavailability of physical cultural resources within the range of close
distance, the issue of adversely affecting the physical cultural property seems not
to be relevant with the project.
Fully complied
17| P a g e
4.0 IMPLEMENTATION OF SOCIAL SAFEGUARDS
4.1 IMPACT ON RESETTLEMENT OF THE PROJECT AFFECTED PEOPLE AND LIVELIHOOD
As the project site is a purchased land of SBPL from private land-owners through willing seller-willing buyer arrangement, there is no issue of resettlement. There was no physical displacement or loss of structure of any project affected people due to the land purchase. So, the project has been categorized as C from Involuntary Resettlement (IR) perspective.
4.2 INSTITUTIONAL ARRANGEMENT ON SOCIAL SAFEGUARD
Mr. S.M. Ali Ahsan, Plant Manager, takes care of social safeguards.
4.3 GRIEVANCE REDRESS MECHANISM
To redress the grievances, SBPL has introduced Grievance Log Book. The Grievance Log
Book is accessible for any internal or external stakeholder, who wants to place grievances in
writing. But in case of confidentiality, there is an arrangement of Grievance Box, where anyone
can place complain in a secret manner. SBPL is committed to resolve any grievance within
15 days of receiving the grievance. Based on the discussion with SBPL officials and adjacent
community members, it has been concluded that during operation phase there is no grievance
case during audit period (January 2019 to December 2019).
4.4 IMPACT ON INDIGENOUS PEOPLE
Based on the primary observation during site visit and secondary sources including BBS4
Census 2011, no habitat of any indigenous community has been reported at Garpara. So, the
project has been categorized as C for Indigenous Peoples (IP) safeguards concluding that
there is no issue about adversely affecting IP neither in construction phase nor in operation
phase.
SBPL has conveyed that they are gender and caste neutral. So, any qualified person coming
from the indigenous community will be equally treated during the recruitment process, and will
be given the same benefits as like as other personnel.
4.5 CHILD LABOUR
The Bangladesh Labour Act 2006 (Act XLII of 2006) also defines the “child” and the
“adolescent” on the basis of age. As per section 2(8) of the Act, a person who has attained
the age of 14 but below the age of 18 is considered to be an adolescent and as per section
2(63), a person not attaining the age of 14 is defined as a “child‟.
According to The National Child Labour Elimination Policy 2010, following rights are to be
complied with, in regard of addressing child labour Issue
4 BBS stands for Bangladesh Bureau of Statistics
18| P a g e
Employing children according to the age determined by the Acts and not to employ children below 14 years as a regular employee;
Ensuring the children at domestic work not to perform any hazardous work and providing them with proper food and accommodation, education, recreation since they work full time; and
Refraining child workers from physical, mental, sexual persecution and abuse.
SBPL has been found to be careful about the child labour issue. So, neither in construction
phase nor in operation phase, no child has been found to be engaged in the project activities.
19| P a g e
4.6 PUBLIC CONSULTATION AND DISCLOSURE OF INFORMATION
I. Public Consultation and major findings
As part of environmental and social compliance, the respective official of IDCOL consulted
with local respondents for a number of occasions during the reporting period. Photographs of
consultation have been provided in Annex-13.
The major findings of public consultation are as follows:
local people do not have specific concern about project-personnel or project activity.
they are pleased with the measures of SBPL to mitigate noise issue
II. Response from SBPL
In response, the SBPL official has ensured that they are considering the noise issue with due
importance.
III. Disclosure
SBPL may think for more structured approach to disclose the grievance redress aspects,
results of environmental monitoring and any other issue (as seems relevant during operation
phase).
4.7 ENHANCEMENT
SBPL acknowledges the importance of satisfactory relationship to adjacent communities.
Accordingly, it has extended various types of cooperation such as:
monetary support to adjacent religious and academic institutions
funding support for medical-treatment
20| P a g e
5.0 CORRECTIVE ACTION PLAN
SBPL has been found to properly comply with the EMP. They have been found to maintain
the required mitigation measures to address the potential impacts including noise and air
pollution. From social safeguard perspective, it has been found that there is no significant
grievance neither from any internal stakeholder nor from any external stakeholder. In addition,
SBPL has been found to extend various types of social welfare services to the
communities.however, SBPL is required to deploy a full-time EHS official as early as possible.
21| P a g e
6.0 CONCLUSION
Based on the findings of environmental and social compliance audit, it can be concluded that
SBPL has been found to satisfactorily complying with environmental and social safeguards.
24| P a g e
Annex 3: Project risk screening checklist of ESSF, IDCOL
Sl.
no
Environmental and social risks rating criteria Response Remarks
Yes No
01
For new projects, does the project have any pending compliance such as
Location and Environmental Clearance based on its category (Red,
Orange-A, Orange-B and Green), from the DOE?
02
Is the project located in the immediate vicinity (likely to adverse impact)
of environmentally critical areas (national wetlands, wildlife habitats,
important bird areas, and protected areas)
03 Does the project construction and/or operation lead to environmental
impacts that are diverse, irreversible and/or unprecedented in nature?
04 Does the project require involuntary resettlement that results in loss of
land or livelihoods or physically displaces more than 200 persons?
05
Is the project site on or in immediate vicinity of socially vulnerable or
Indigenous People IP) owned or occupied land and has the potential to
cause an adverse impact on their culture and identity?
06 Is the project vulnerable to climate change related impacts?
07
Does the Borrower have a documented Policy on E&S Performance?
08
Does the Borrower have dedicated human resources to address E&S
performance?
09
Has the Borrower established and implemented Environmental, Health &
Safety Management Systems and Social Accountability Systems for the
Project SPV or in the parent company?
27| P a g e
Annex 6: Application of signage
Photograph: Arrangement of signage for occupational safety
28| P a g e
Annex 7: Current status of project (external view)
Photographs: Transformer and some important installations
29| P a g e
Annex 8: Current status of project (internal view)
Photographs: Control room, generators and fuel treatment plant
31| P a g e
Annex 10: Housekeeping
Photographs: Status of internal housekeeping
Photographs: Status of external housekeeping
32| P a g e
Annex 11: Embankment protection arrangement
Photographs: Embankment protection arrangement